DATEATTACHMENT 18300.10 CHG XX
Sections 2 and 3, and review the Interface section, Section 4, to determine if any concerns were documented. Plan inspection activities so that these concerns can be answered.
Section 2, Management Responsibility and Authority Observables. This section will allow a CMT to document the person(s) with the authority to change a program and the person(s) responsible for the accomplishment of the program. This information can be useful in determining the impact of key personnel changes at an air carrier. This section should be assigned at the discretion of the principal and specific instructions should be provided to the assigned inspector as to whom or where (corporate, main base, line station) the questions should be directed.
EPI Drop Down Menus. Each section of the EPI has a unique drop down menu. The sections of the SAI are analogous to the selections of the Section 1 Drop Down Menu in providing a structured review of an air carrier’s operation. Non-ATOS inspectors using the 1.x EPI should review the selections of the Section 1 Drop Down Menu prior to accomplishing the observations necessary to accomplish the validation function. The drop down is constructed from the components of, and the safety attributes of, a good system. Should failures occur during the performance assessment, most likely it will be attributed to at least one of these selections. Dependant upon the information gathered, principals may choose to modify their risk action plans accordingly.
9.SAI/EPI RESPONSE OPTIONS. There are three response options available to ATOS inspectors accomplishing SAI and EPI activities, “Yes,” “No,” or “N/A.” If a question has the “N/A” response option, it indicates that the regulatory requirement is type specific, equipment specific, or that the regulation allows for an alternate means of compliance. Determine if the question applies and only answer the question once if it is not applicable. EPI Section 1 questions that have an “N/A” response option will also have the “N/A” response option for the associated controls and process measurements questions in the corresponding 1.x SAI. Supporting information may be captured as a comment, non-ATOS inspectors may add text to the questions of the word version of the element you are working and this annotated record should be saved/archived.
11.“YES” ANSWERS TO THE SAI QUESTIONS. Knowing where to find the information contained in an applicant/certificate holder’s manual system is half the battle. When answering the questions, a comment should be made to include the location of the information in the applicant/certificate holder’s manual in the word document that will be archived at the end of the evaluation. This information will be helpful in researching and planning future activities, and will be invaluable should there be changes to the CMT personnel/principals. This information should reduce the amount of time it takes new personnel assigned to the certificate to get acquainted with the air carrier’s policies and procedures.
13.WHAT TO DO WITH “NO” ANSWERS GATHERED WITH 1.X SAIS. The 1.x SAI will assist you in determining if the technical content of a program is adequate, but it stops short of seeing the actual program in operation. The EPI is intended to perform that function. That does not mean that the 1.x SAI will not identify or provide information that could be used to identify risks with an applicant’s/certificate holder’s program. For risk assessment purposes, “No” answers in the procedures section can be more significant than “No” answers in the remaining sections. When conducting a manual review with a 1.x SAI, “No” responses to the element specific questions in the procedures section will indicate that the applicant’s/certificate holder’s manual content does not meet or is contrary to the regulatory requirements for a given element. While “No” answers in the remaining sections provide more useful information for determining surveillance requirements or inspection activities. “No” answers to a question in Sections 2-5 might be used to formulate tabletop and or proving flight scenarios to test the effectiveness of the air carrier’s procedures. If the air carrier is an existing carrier requesting approval for a program change, the same holds true except that surveillance of the ongoing operation will have to be used in lieu of table top and proving runs to test the effectiveness of the requested change. This is the hand off from the verification function to the validation function, and EPI activities will be focused on the risks identified during the manual review.
15.WHAT TO DO WITH “NO” ANSWERS COLLECTED WITH 1.X EPIS. No answers have to be evaluated to determine if the information they provide identify weaknesses in the performance of the air carrier’s program, or the air carrier’s program design. The drop down menu for Section 1, selections will identify if the negative observations were attributed to a lack of resources